Controlled-Substance Discrepancy and Mobile Clinic Transport
A New Mexico small-animal clinic performs a biennial controlled-substance inventory. The ketamine log shows 18 mL remaining in a 50 mL vial, but the physical count is 11 mL. The butorphanol 10 mg/mL log shows 6 mL remaining, but only 4 mL is in the safe. A registered veterinary technician admits drawing up ketamine for three cat castrations last week without recording the amounts, and says she took a 10 mL vial of ketamine to a weekend mobile vaccine clinic in another town. The clinic has no separate DEA registration for that location. The practice owner is out of town. The lead technician must determine what to do before the owner returns. The clinic's DEA registration is current, and the state board requires controlled substances to be kept in a locked cabinet.
1. Identify the compliance problems and outline the immediate actions the lead technician should take. Include reporting considerations.
Read the worked answer
There are two controlled-substance discrepancies: ketamine is 7 mL short and butorphanol is 2 mL short. The technician's admission explains part of the ketamine loss but not all of it. Unrecorded doses are still a recordkeeping violation, and taking ketamine to an unregistered mobile site is a separate serious issue. Immediately secure the safe, stop further use of the affected vials, preserve the log and vials, and do not alter or backfill records. Notify the practice owner and the veterinarian in charge. Because theft or significant loss is possible, the DEA registrant must report on DEA Form 106 within one business day of discovery and notify the state board as required. A DEA registration is location-specific; the mobile clinic cannot use the main clinic's registration unless the activity is covered by that registration.
2. What corrective actions and documentation should follow? What should the lead technician tell the registered technician about her conduct?
Read the worked answer
Perform a full audit of all controlled substances, not just the two vials. Use a second person to witness counts and document the discrepancy, interviews, and actions. Retrain the technician on logging each dose at the time it is drawn, witnessing and documenting waste, never transporting controlled substances without authorization, and the location-specific DEA registration. Correct errors with a single line, initials, date, and reason; never obliterate or backfill. Set a schedule for periodic counts, keep records for at least two years under federal rules while checking New Mexico requirements, and store drugs in the locked cabinet. The lead technician should tell the registered technician that her actions created reportable discrepancies and that the practice owner and state board may review her conduct. The owner should decide whether the incident is reportable as employee theft and consult the state board about the technician's conduct and any practice restrictions.